It is specifically prohibited for an entity to dilute to a concentration
level that would render a substance below regulatory limits.
-----Original Message-----
From: radsafe-bounces at health.phys.iit.edu
[mailto:radsafe-bounces at health.phys.iit.edu] On Behalf Of Robert Bradley
Sent: Wednesday, November 07, 2012 3:59 PM
To: The International Radiation Protection (Health Physics) Mailing List
Subject: Re: [ RadSafe ] Fwd: Soil Blending
Naively, this just sounds like an application of "dilution" as a means of
reducing concentration. Why would this not be acceptable to a regulator?
- - RPB
On Wed, Nov 7, 2012 at 6:50 PM, Chris Alston <achris1999 at gmail.com> wrote:
> Pete
>> It will certainly be interesting to hear what Radsafers have to say,
> but why not call Region IV (?) and ask them what their take on the
> hypothetical is?
>> Regardless, please let us know what develops.
>> Cheers
> cja
>>> ---------- Forwarded message ----------
> From: Peter Collopy <chaosforthefuture at yahoo.com>
> Date: Wed, Nov 7, 2012 at 6:22 PM
> Subject: [ RadSafe ] Soil Blending
> To: radsafe <radsafe at health.phys.iit.edu>
>>>>> I have been working with a client who has somehow latched onto the
> idea they could blend soil to lower the overall radionuclide
> concentations in soil to make the soil acceptable for disposal on the
> site of origin. In my opinion the only way that could be done would be
> to submit to the NRC or the agreement state an exemption request to do
> that type of operation. My client has asked, and as a dutiful
> consultant I am acceding (reluctantly) to their wishes, that I find
> out if anyone has ever been allowed to do a purposeful blending
> operation with the objective of on-site soil disposal. So here are my
> two questions:
>> 1. Have you ever heard of soil blending being allowed on a U.S. site
> for the purpose of lowering the concentrations to below the DCGL and
> thus meeting free release criteria for the site.
>> 2. If the answer to 1 above is yes did they apply for an exemption
> from the NRC or agreement state or did they simply do the work as part
> of an approved Decommissioning Plan?
>> If you wish to keep any info on the QT just email me directly or call
> but keep in mind I am on the west coast so early moring risers on the
> east coast try not to call at 7:00 your time.
>> Thanks for any info in advance
>>> Pete C
>> Peter Collopy, CIH, CHP, CSP
> Director, Entropy Control
> Chaos for the Future
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